Introduction

This statement has been published in accordance with section 54(1) of the Modern Slavery Act 2015 (the “Act”). It sets out the steps that The Kee Safety Group (the “company”) have taken to prevent modern slavery and human trafficking within its business and supply chains. The statement applies for the financial year ending 31st December 2021.

Organisational structure

The Kee Safety Group, specialising in Collective and Personal Fall Protection systems - roof edge guardrail and skylight protection, horizontal life line, walkway and portable anchor products. Engineered Guardrail Solutions, Bespoke Access Platforms, Self-Closing Gates and Industrial Roof Access Systems. Easi-Dec temporary work platforms and ladder products. Kee Klamp®, Kee Lite® & Kee Access® tubular fittings. Beam Clamp® & Box Bolt® steel to steel connection products. Safety services such as safety system recertification.

Our Commitment

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to implementing and enforcing effective systems and controls to help ensure modern slavery is not taking place anywhere in our own business or our supply chains.

We are therefore continuing to implement appropriate controls across a number of areas within our business, including our supplier policies, contractual processes, training and reporting. Our Quality and Risk Team continues to work in conjunction with other areas of the company (including our subject matter specialists in Human Rights and Modern Slavery) to help ensure the intent of the Act is met within our own business and our supply chains.

We also believe in the importance of transparency creating positive change and setting out the way we wish to operate both between ourselves, between the company and our customers and, also, between the company and society. All our directors, staff and contractors are required to confirm they have read and understood our Global Code of Conduct as part of the annual compliance exercise.

Our Policies

Kee Safety Group Ethical Policy Statement and Anti-Slavery and Human Trafficking Policy

Our Ethical Policy and Anti-Slavery and Human Trafficking Policy, are approved by our UK Executive Board, and applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. The company will be monitoring its use and effectiveness, dealing with any queries about it, and considering internal control systems and procedures to ensure they are effective in countering modern slavery. 

The company has a zero-tolerance approach to modern slavery that will be communicated to suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. In addition, we may terminate our relationship with individuals and organisations working on our behalf if they breach this policy.

Suppliers

Our approved supplier contracts shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015; and comply with the Anti-slavery policy and maintain throughout the term of this agreement its own policies and procedures to ensure its compliance”.

We expect our suppliers to implement due diligence procedures for their permitted direct subcontractors, and suppliers and other participants in its supply chains, to ensure that there is no slavery or human trafficking in its supply chains. The clause enables the company where appropriate to undertake audits of suppliers’ records and any other information and to meet with suppliers’ personnel to review their compliance with its obligations under this clause. The clause also gives the company the right to terminate the agreement with immediate effect if the supplier commits a breach of the anti-slavery policy or this clause or applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015.

Employees

Within our company we are committed to paying people fairly and properly for the work that they perform.

Strong values have been at the heart of our organisation since its creation. They guide us in our daily actions, providing a common base of values that all team members share and respect.

Our values include the following three specific values relating to our work and ethos, and how it affects the wider global environment:

• Integrity - Ethical and moral rigour guide how we work and assist our clients;
• Responsibility - We treat the challenges of our clients as our own and we care about how our work may affect our communities; and
• Diversity and respect for individuals - Looking beyond borders and cultural differences, we make respect for the individual the cornerstone of all human relations.

Our standards include the following:

• We act with integrity and comply with the law, professional standards and the company’s policies and procedures applicable to our work;
• We consult when questions of ethics arise;
• We speak up when we see or hear of behaviour that causes us concern on ethical grounds or fails to uphold our values. Team members who speak up in good faith are assured that they will not suffer any adverse consequences as a result of their doing so; and
• We develop and promote thought leadership on issues of importance to the business, financial communities and wider society, including in the area of human rights.

Recruitment

The majority of our workforce is employed on a permanent or contract basis. Our recruitment processes include direct advertising on our website, using reputable agencies, and also direct referrals from staff members. All employees who join the company are subject to checks, including the verification of identity, right to work, references and evidence of qualifications where appropriate. Similar checks are also undertaken for contractors.

Our Training and Awareness

All new starters are required to complete training on the following Modern Slavery Statement, Kee Safety Group Ethical Policy Statement and Anti-Slavery and Human Trafficking Policy as part of their induction programme. This mandatory training and will be refreshed annually to ensure an up-to-date knowledge of the subject. The introduction of focussed training for those in the company involved in contracts and procurement activities will also be considered.

Further Activities

In connection with the Act we continue to consider our procedures to identify, and manage, risk from internal and external factors, including modern slavery and human trafficking. Our Enterprise Risk Management Framework and categories of risk include, for example, regulatory risks, reflecting the emphasis and importance of risks in these areas and the potential impact they have on the success of the company, and society as a whole.    

Future Commitments

In the next year we will continue to develop our policies in this area by:

• Conducting due diligence processes during our onboarding process for new key suppliers to ensure their values and processes align with our policies;
• Refreshing the mandatory Modern Slavery training module and considering additional training for appropriate support staff.

This statement has been approved by the UK Executive Board on behalf of The Kee Safety Group. It will be reviewed and updated annually.

Mark Colquhoun
Group HSE Director

15 December 2021